NOTICE OF PRIVACY PRACTICE

Faith & Family Hospice (FFH) takes the privacy of your health information seriously. FFH is required by law to maintain that privacy and to provide you with this Notice of Privacy Practices. This Notice is provided to tell you about our duties and practices with respect to your information. THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

USES AND DISCLOSURES OF HEALTH INFORMATION

Faith & Family Hospice (FFH) may use your health information for purposes of providing you treatment, obtaining payment for your care, and conducting health care operations. Your health information may be used or disclosed for other purposes only after FFH has obtained your written authorization. FFH has established a policy to guard against unnecessary disclosure of your health information and does not sell health information.

THE FOLLOWING IS A SUMMARY OF CIRCUMSTANCES UNDER WHICH AND PURPOSES FOR WHICH YOUR HEALTH INFORMATION MAY BE USED AND DISCLOSED:

To Provide Treatment, FFH may use your health information to coordinate care within FFH and with others involved in your care, such as your attending physician, members of FFH interdisciplinary team, and other health care professionals who have agreed to assist FFH in coordinating care. For example, physicians involved in your care will need information about your symptoms to prescribe appropriate medications. FFH also may disclose your health care information to individuals outside of FFH involved in your care including, pharmacists, suppliers of medical equipment, or other health care professionals that FFH uses to coordinate your care. With your authorization, FFH may also disclose information about your care to family members or clergy for whom you have provided written authorization.

To Obtain Payment. FFH may include your health information in invoices to collect payment from third parties for the care you may receive from FFH. For example, FFH may be required by your health insurer to provide information regarding your health care status so that the insurer will reimburse you or FFH. FFH also may need to obtain prior approval from your insurer and may need to explain to the insurer your need for hospice care and the services that will be provided to you.

To Conduct Health Care Operations. FFH may use and disclose health care information for its own operations to facilitate the function of FFH and as necessary to provide quality care to all FFH’s patients. Health care operations include such activities as:
• To meet legally required health care information reporting requirements
• Quality assessment and improvement activities
• Activities designed to improve health or reduce health care costs.
• Protocol development, case management and care coordination.
• Contacting health care providers and patients with information about treatment alternatives and other related functions that do not include treatment.
• Professional review and performance evaluation.
• Training programs including those in which students, trainees or practitioners in health care learn under supervision.

NOTICE OF PRIVACY PRACTICES

• Training of non-health care professionals.
• Accreditation, certification, licensing or credentialing activities.
• Review and auditing, including compliance reviews, medical reviews, legal services and compliance programs.
• Business planning and development including cost management and planning related analyses and formulary development.
• Business management and general administrative activities of FFH.
• Fundraising for the benefit of FFH and certain marketing activities.

For example FFH may use your health information to evaluate its staff performance, combine your health information with other Hospice patients in evaluating how to more effectively serve all Hospice patients or report legally required information to a state or federal agency, to disclose your health information to Hospice staff and contracted personnel for training purposes, use your health information to contact you as a reminder regarding a visit to you, and community information mailings (unless you tell us you do not want to be contacted). FFH will not release all or any part of its mailing list to any outside organization or individual. FFH does not market health related products or services to patients nor will FFH give information to a telemarketer, door-to-door salesperson, or other marketer it may hire.

For Fundraising Activities. FFH may use information about you including your name, address, phone number and the dates you received care at FFH to contact you or your family to raise money for FFH. If you do not want FFH to contact you or your family, notify the Compliance Officer and indicate that you do not wish to be contacted. In no event will FFH sell patients’ personal health information and such practice requires an authorization from you in advance.

Federal privacy rules allow or require FFH to use or disclose your health information without your consent or authorization for a number of reasons: When Legally Required: FFH will disclose your health information when it is required to do so by any Federal, State or local law.

When There Are Risks to Public Health. FFH may disclose your health information for public activities and purposes to:
• Prevent or control disease, injury or disability, report disease, injury, vital events such as birth or death and the conduct of public health surveillance, investigations and interventions.
• To report adverse events, product defects, to track products or enable product recalls, repairs and replacements and to conduct post-marketing surveillance and compliance with requirements of the Food and Drug Administration.
• To notify a person who has been exposed to a communicable disease or who may be at risk of contracting or spreading a disease.
• To an employer about an individual who is a member of the workforce as legally required. To Report Abuse, Neglect or Domestic Violence. FFH is allowed to notify government authorities if FFH believes a patient is the victim of abuse, neglect or domestic violence. FFH will make this disclosure only when specifically required or authorized by law or when the patient agrees to the disclosure.

To Conduct Health Oversight Activities. FFH may disclose your health information to a health oversight agency for activities including audits, civil administrative or criminal investigations, inspections, licensure or disciplinary action. FFH, however, may not disclose your health information if you are the subject of an investigation and your health information is not directly related to your receipt of health care or public benefits.

In Connection with Judicial and Administrative Proceedings. FFH may disclose your health information during any judicial or administrative proceeding in response to an order of a court as expressly authorized by such order. For Law Enforcement Purposes. FFH may disclose your health information to a law enforcement official for law enforcement purposes as follows:
• As required by law for reporting of certain types of wounds or other physical injuries pursuant to the court order, warrant, subpoena or summons or similar process.
• For the purpose of identifying or locating a suspect, fugitive, material witness or missing person.
• Under certain limited circumstances when you are the victim of a crime.
• To a law enforcement official if FFH has a suspicion that your death was the result of criminal conduct including criminal conduct at FFH.
• In an emergency to report a crime.

To Coroners and Medical Examiners. FFH may disclose your health information to coroners and medical examiners for purposes of determining your cause of death or for other duties, as authorized by law.

To Funeral Directors. FFH may disclose your health information to funeral directors consistent with applicable law and if necessary, to carry out their duties with respect to your funeral arrangements. If necessary to carry out their duties, FFH may disclose your health information prior to and in reasonable anticipation, of your death.

For Organ, Eye or Tissue Donation. FFH may use or disclose your health information to organ procurement organizations or other entities engaged in the procurement, banking or transplantation of organs, eyes, or tissue for the purpose of facilitating the donation and transplantation.

For Research Purposes. FFH may, under very select circumstances, use your health information for research. Before FFH discloses any of your health information for such research purposes, the project will be subject to an extensive approval process. FFH will ask your permission if any researcher will be granted access to your individually identifiable health information.

In the Event of a Serious Threat to Health or Safety. FFH may, consistent with applicable law and ethical standards of conduct, disclose your health information if FFH, in good faith, believes that such disclosure is necessary to prevent or lessen a serious and imminent threat to your health or safety or to the health and safety of the public.

For Specified Government Functions. In certain circumstances, the Federal regulations authorize FFH to use or disclose your health information to facilitate specified government functions relating to military and veterans, national security and intelligence activities, protective services for the President and others, medical suitability determinations and inmates and law enforcement custody.

For Worker’s Compensation. FFH may release your health information for worker’s compensation or similar programs.

FAITH & FAMILY HOSPICE NOTICE OF PRIVACY PRACTICES
Other than what is stated above, FFH will not disclose your health information other than with your written express authorization. If you or your representative authorizes FFH to use or disclose your health information, you may revoke that authorization in writing at any time.

YOUR RIGHTS WITH RESPECT TO YOUR HEALTH INFORMATION

You have the following rights regarding your health information that FFH maintains:
• Right to request restrictions. You have the right to request restrictions on certain uses and disclosures of your health information. You have the right to request a limit on FFH’s disclosure of your health information to someone who is involved in your care or the payment of your care. FFH is not required to agree to your request, unless your request is for a restriction on a disclosure to a health plan for purposes of payment or health care operations (and is not for purposes of treatment) and the medical information you are requesting to be restricted from disclosure pertains solely to a health care item or service for which you have paid out of pocket in full. If you wish to make a request for restrictions, please contact the Compliance Officer.
• Right to receive confidential communications. You have the right to request that FFH communicate with you in a certain way. For example, you may ask that FFH only conduct communications pertaining to your health information with you privately with no other family members present. If you wish to receive confidential communications, please contact the Compliance Officer. FFH will not request that you provide any reasons for your request and will attempt to honor your reasonable requests for confidential communications.
• Right to inspect and copy your health information. You have the right to inspect and copy your health information, including billing records. A request to inspect and copy records containing your health information may be made to the Compliance Officer. If you request a copy of your health information, FFH may charge a reasonable fee for copying and assembling costs associated with your request. You have the right to request that FFH provide you, an entity, or a designated individual with an electronic copy of your electronic health record containing your health information. FFH may require you to pay the labor costs incurred by the Hospice in responding to your request.
• Right to amend health care information. If you or your representative believes that your health information records are incorrect or incomplete, you may request that FFH amend the records. That request may be made if the information is maintained by FFH. A request for an amendment of records must be made in writing to the Compliance Officer. FFH may deny the request if it is not in writing or does not include a reason for the amendment. The request also may be denied if your health information records were not created by FFH, if the records you are requesting are not part of FFH’s records, if the health information you wish to amend is not part of the health information you or your representative are permitted to inspect and copy, or if, in the opinion of FFH, the records containing your health information are accurate and complete.
• Right to an accounting. You or your representative have the right to request an accounting of disclosures of your health information made by FFH for any reason other than for treatment, payment, or health operations. The request for an accounting must be made in writing to the Compliance Officer. The request should specify the period for the accounting starting on October 1st, 2022. Accounting requests may not be made for periods of time more than six years. FFH would provide the first accounting you request during any 12-month period without charge. Subsequent accounting requests may be subject to a reasonable cost-based fee.
• Right to a paper copy of this notice. You or your representative has a right to a separate paper copy of this Notice at any time even if you or your representative has received this Notice previously. To obtain a separate paper copy, please contact the Compliance Officer. Anyone may also obtain a copy of the current version of FFH’s Notice of Privacy Practices at its website, www.hospicefamily.com.
• In the event of a Breach of Health Information. FFH is required to timely notify you in the event of a breach that poses a significant risk of financial, reputation or other harm to you. Any such notification will include a description of what happened, the types of information involved in the breach, steps we have taken and will take to mitigate any potentially harmful effects of the breach and further information for you on how to protect yourself following the breach.

DUTIES OF FAITH & FAMILY HOSPICE

FFH is required by law to maintain the privacy of your health information and to provide to you and your representative this Notice of its Duties and privacy practices. FFH is required to abide by terms of this Notice as may be amended from time to time. FFH reserves the right to change the terms of its Notice and to make the new Notice provisions effective for all health information that it maintains. If FFH changes its Notice, FFH will provide a copy of the revised Notice to you or your appointed representative. You or your personal representative will have the right to express complaints to FFH and to the Secretary of Health and Human Services if you or your representative believes that your privacy rights have been violated. Any complaints to FFH should be made in writing to the Compliance Officer. FFH encourages you to express any concerns you may have regarding the privacy of your information. You will not be retaliated against in any way for filing a complaint.

IF YOU HAVE ANY QUESTIONS REGARDING THIS NOTICE, PLEASE CONTACT THE COMPLIANCE OFFICER OF FAITH & FAMILY HOSPICE.

CONTACT PERSON
FFH’s contact for all issues regarding patient privacy and your rights under the Federal privacy standards is:
Compliance Officer
Faith & Family Hospice
420 Lakeside Ave Suite 203
Marlborough, MA 01762
(508)-485-4555
EFFECTIVE DATE
This Notice is effective October 1, 2022.